## Facts

- John J. Mattingly brought a federal civil rights action seeking damages stemming from his arrest and ten-day incarceration under a state-court order for body attachment.
- The litigation initially included Cook County officials and unnamed City of Chicago employees; Mattingly later amended to add the City of Chicago and Willie Miranda.
- The Cook County defendants settled and were dismissed, leaving the City and Miranda as remaining defendants.
- At a settlement conference attended by Mattingly and all counsel, the parties agreed the City would pay Mattingly $32,500 and the agreement was placed on the record; the parties also contemplated filing an agreed judgment against the City and dismissing Miranda.
- After the conference, the parties exchanged drafts of a stipulation and general release and later agreed on revisions that both sides stated reflected the terms reached at the settlement conference.
- Mattingly refused to sign the final written documents despite acknowledging they matched the agreed settlement terms and despite counsel’s advice; he sought to add unrelated matters to the case.
- The City moved to enforce the settlement; Mattingly opposed, arguing no binding agreement existed and asserting the draft documents were unfair or unlawful.

## Issues

1. Whether the settlement agreement reached in court and placed on the record constituted an enforceable contract despite Mattingly’s later refusal to sign written settlement documents.
2. Whether Mattingly could avoid enforcement based on later dissatisfaction, asserted unfairness of the memorializing documents, or a desire to add unrelated claims.

## Decision

- The court granted the City’s motion to enforce the settlement.
- The court held the November 23, 1994 settlement was a valid and enforceable contract.
- The court ordered the parties to proceed according to the settlement’s terms, including entry of the contemplated judgment against the City and dismissal of the individual defendant.

## Legal Principles

- Settlement agreements are contracts analyzed under ordinary contract principles, including offer, acceptance, and mutual assent to material terms.
- An oral settlement made in court and placed on the record is binding when the parties assent to the material terms, even if they plan to later reduce the agreement to writing.
- A party’s refusal to sign later-prepared releases or stipulations does not negate an already-formed settlement unless execution was an agreed condition to contract formation.
- Post-settlement regret, dissatisfaction, or a desire to add new and unrelated claims is not a basis to rescind or avoid enforcement absent a showing of fraud, duress, or mistake.

## Conclusion

The court enforced the parties’ recorded in-court settlement because the material terms were agreed upon and assented to at the settlement conference, and Mattingly’s later refusal to sign memorializing documents—based on dissatisfaction and a desire to add unrelated claims—did not defeat contract formation or provide a recognized ground to set the agreement aside.


Mattingly v. City of Chicago, 897 F. Supp. 375 (N.D. Ill. 1995)